Accountant malpractice is very similar to legal malpractice. Continuous representation is one aspect. Here is an Appellate reversal of a New York County Supreme Court case where Justice Kornreich found continuous representation, but the AD reversed in Booth v. Kriegel.
"Accountant I. Stanley Kriegel admits that for 17 straight years he failed to advise his client, actress Connie Booth — a U.S. citizen who lives in the United Kingdom — that a 1985 British-American agreement exempted her from paying Social Security taxes.
Yesterday, the Appellate Division, First Department, reversed, and dismissed Ms. Booth’s case.
"We hold that the continuous representation doctrine does not apply under these facts because, regardless of the common mistake affecting the tax returns, each return was a separate and discrete transaction," Justice David Friedman (See Profile) wrote for the unanimous panel in Booth v. Kriegel, 9312. "Therefore, any claim arising from the preparation of each successive tax return accrued, and the statute of limitations on that claim began to run, upon the completion of the services relating to that return." "